Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Disallowance of interest u/s 36(1)(iii) - assessee has a stake in the performance and profit making of wholly owned subsidiaries - it cannot be denied that the advancement of loan is in connection with assessee’s business - the difference in the interest rate between the borrowed funds and loans advanced is only 3.25% and the advanced of loan in connection with its business - no disallowance
Disallowance of interest u/s 36(1)(iii) - assessee has a stake in the performance and profit making of wholly owned subsidiaries - it cannot be denied that the advancement of loan is in connection with assessee’s business - the difference in the interest rate between the borrowed funds and loans advanced is only 3.25% and the advanced of loan in connection with its business - no disallowance
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